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W.P.(MD)No.670 of 2026

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

DATED : 29.01.2026

CORAM

THE HONOURABLE MR.JUSTICE KRISHNAN RAMASAMY

W.P.(MD)No.670 of 2026

1.Rooba

2.Muthukumar S

... Petitioner

Vs.

The Sub-Registrar

North Veeravanallur

Tirunelveli.

... Respondents

Prayer:

Writ Petition filed under Article 226 of the Constitution of India

praying to issue a Writ of Certiorarified Mandamus, calling for the

records relating to the impugned order of the respondent in Refusal

Check Slip No. RFL/North Veeravanallur/44/2025 dated 14.10.2025 and

quash the same and consequently direct the respondent to register and

release the document in favour of 1st petitioner within the time fixed by

this Honble Court.

For Petitioner : Mr.H.Arumugam

for Mr.S.Packiya Muthu

For Respondent : Mr.V.Omprakash, GA

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W.P.(MD)No.670 of 2026

ORDER

This writ petition has been filed challenging the refusal check slip

dated 14.10.2025 issued by the respondent.

2. The learned counsel for the petitioner would submit that in this

case, the 1^st petitioner is the purchaser and 2^nd petitioner is the seller of

the subject property. The 2^nd petitioner intends to sell 31 cents of

agricultural land to the 1^st petitioner and presented the sale deed dated

10.10.2025. However, the respondents had refused to register the same

by stating that the subject land is an unapproved layout and hence, there

is a bar under Section 22A of the Registration Act to register any

document pertaining to the said land.

3. In reply, the learned Government Advocate appearing for the

respondent would submit that during a previous occasion, subsequent to

the registration of a document, pertaining to the subject land, an

objection was received from a 3^rd party by stating that it is an

unapproved layout. Now, the 2^nd petitioner intends to sell the very same

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W.P.(MD)No.670 of 2026

subject land to the 1^st petitioner and presented the sale deed dated

10.10.2025. Therefore, based on the objection received, the respondent

had issued the refusal check slip dated 14.10.2025 by citing the bar

under Section 22A of the Registration Act.

4. Heard the learned counsel for the petitioner and the learned

Government Advocate appearing for the respondent and also perused the

entire materials available on record.

5. In the case on hand, initially, the 2^nd petitioner had purchased

the subject property, comprising 31 cents of agricultural land, vide sale

deed dated 08.09.2021, from her vendor. Now, the 2^nd petitioner intended

to sell the said subject land to the 1^st petitioner, by virtue of sale deed

dated 10.10.2025. However, the respondent had refused to register the

same vide impugned refusal order dated 14.10.2025, citing the reason

that the subject land is an “unapproved layout” and thus, in terms of

Section 22A of the Registration Act, 1908, there is a specific bar in

registering the sale deed pertaining to the subject land.

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W.P.(MD)No.670 of 2026

6. According to the petitioners, the subject land is not house site

but an agricultural land. The sale deed dated 10.10.2025 was executed

by the 2^nd petitioner is only with regard to the 31 cents of agricultural

land and hence, it will not be considered as “plot/layout” to attract the

provisions of Section 22A of the Registration Act, 1908. In this regard,

they referred the clarification dated 16.03.2020 issued by Principal

Secretary of Registration Department.

7. A perusal of the provisions of Section 22A and the aforesaid

clarification makes it clear that the bar under Section 22A will apply

only if there is any layout formed in the subject land. However, in this

case, the subject property is an agricultural land and hence, the question

of forming layout will not come into picture. In such case, the

respondent will not have any impediment for registration of any

document per